The Canadian pension’s website currently hosts audit statements from 2004-2016 and Annual Reports from 2013-2016. The audit reports are about 24 pages long and include the plan’s balance sheet, a summary description of the plan and associated notes. The annual reports are intended to be reports to the membership and are more readable than the audit reports. They summarize the information from the audit reports and provide a discussion of the fund’s situation and future. The Canadian plan’s website contains much more historical information than the AFM-EPF’s site.
The Annual Reports are beautiful and a model of clarity. They provide more information in a more useful form for the typical fund participant than the one-page plan funding notice we are all used to receiving from American pension plans such as the AFM-EPF. The greater transparency of the U.S. system does make it possible for plan participants to assemble comparable information for themselves, but that would require a signiﬁcant amount of time and eﬀort. We applaud the recent improvements made by the AFM-EPF in this area, but they still need to do better to catch-up with Canada.
The Canadian audit statements are disappointing. They contain a tiny subset of the information we are accustomed to getting from U.S. pensions plans. Missing from Pension-CANADA: government ﬁlings, actuarial schedules, actuarial reports (including the crucial actuarial assumptions), compensation for each employee, compensation for each ﬁnancial adviser. Well, you get the picture. Without this information, a thorough evaluation of all aspects of the Canadian pension plan is impossible.
In an attempt to acquire some of the missing information, we contacted the Canadian pension plan. We were especially interested in obtaining the discount rates used by the fund actuary. Jill D. Giustino, Director of Administration, told us that our request would have to be approved both by the Board of Trustees as well as the Fund’s Actuary. About a month later, our application was politely denied.
We then contacted the Financial Services Commission of Ontario (FSCO). We asked for access to the ﬁlings of the Canadian pension plan, explaining that those were available to any person for U.S. pension plans. Sobha Haumeer, Pension Analyst at the FSCO also turned down our request, citing Ontario law. Apparently only “plan beneﬁciaries” can obtain such information. There is an option in Ontario law to have a plan beneﬁciary appoint a representative in writing, who would then have access to plan documents. We haven’t taken that step so crucial plan information remains inaccessible to us and to any other scholars who would be interested in seeing it.
We have also made the same request to the CRA. Months after we made it, we are still waiting for an answer. We do not expect a “yes”.
Based on these experiences, we are forced to conclude that the Ontario pension system is incredibly opaque and very much in need of reform. The situation in the U.S. is vastly superior.